RESPONDENT IS A CORPORATION DOING BUSINESS IN THE STATE OF TEXAS. AT ALL TIMES RELEVANT TO THIS COMPLAINT, RESPONDENT HAS BEEN THE OWNER AND OPERATOR OF A SYNTHETIC CHEMICAL MANUFACTURING COMPLEX LOCATED IN TEXAS CITY, TEXAS (THE FACILITY ). VINYL CHLORIDE IS AMONG THE CHEMICALS PRODUCED AT THE FACIL- ITY. THE FACILITY IS INVOLVED IN THE HANDLING AND PRODUCTION OF BENZENE. ON OR ABOUT DEC. 1 THROUGH ON OR ABOUT DEC. 17, 1992, EPA CONDUCTED AN INSPECTION OF THE FACILITY ( THE INSPECTION ), PURSUANT TO SECTION 114 OF THE ACT, 42 U.S.C. SEC. 7414. AT THE TIME OF THE INSPECTION, THE FACILITY WAS ENGAGED IN ASBESTOS DEMOLITION OR RENOVATION ACTIVITY, INCLUDING THE REMOVAL OF RACM IN EXCESS OF 80 LINEAR METERS (260 LINEAR FEET) ON PIPES OR 15 SQUARES METERS (160 SQUARE FEET) ON OTHER FACILITY COMPONENTS, OR 1 CUBIC METER (35 CUBIC FEET) OFF FACILITY COMPONENTS WHERE THE LENGHT OR AREA COULD NOT BE MEASURED PREVIOUSLY. THE FACILITY EMITS HAZARDOUS AIR POLLUTANTS AS THAT TERM IS DEFINED. THE FACILITY IS A STATIONARY SOURCE AS THAT TERM IS DE- FINED. VIOLATIONS: COUNT 1: RESPONDENT WAS IN VIOLATIO